Defendant doesn’t get a Franks hearing that the officer knew or should have known that his CI actually went into defendant’s apartment based on video surveillance that allegedly would disprove it. He doesn’t show that the video shows what he claims and it’s conclusive enough on the question. United States v. Deshields, 2021 U.S. Dist. LEXIS 71691 (M.D. Pa. Apr. 14, 2021).
The state’s appeal of suppression of defendant’s medical records obtained by subpoena and not a search warrant is denied where it would not lead to uniformity in the law. State v. Kirchner, 2021 Ark. LEXIS 76 (Apr. 15, 2021).*
On a tracking warrant for an escapee: “The Court finds that these facts, in total, are sufficient to support a finding of probable cause. … The Court also finds that the judicial officer issuing the tracking warrant had a substantial basis for concluding that a search would uncover evidence of wrongdoing, namely Martin’s alleged escape from custody. … [¶] Furthermore, the location data is nevertheless admissible under the good-faith exception. …” United States v. Martin, 2021 U.S. Dist. LEXIS 72477 (D. Minn. Apr. 15, 2021).*